EPA Submits Final Rule on HFC Management | Super Radiator Coils

The Environmental Protection Agency recently submitted the third final rule stemming from 2020’s American Innovation and Manufacturing (AIM) Act, which gave the agency the authority to regulate HFC substances. The first of these rules established a phasedown roadmap, the second outlined refrigerant GWP limits in equipment, with this most recent ruling pertaining to the reclaim, recycling, reuse, and other management of HFC substances.

The latest rule, which was submitted for official publication on September 20^th, would mark the first AIM Act mandate relating to subsection h of the legislation, which concerns the management of regulated substances, with the previous two rules pertaining to the “technology transitions” subsection.

The rule, titled “Phasedown of Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes under the American Innovation and Manufacturing Act of 2020,” includes – among other measures – provisions around the establishment of an “emissions reduction and reclamation program for the management of hydrofluorocarbons that includes requirements for leak repair and installation and use of automatic leak detection systems for certain equipment using refrigerants containing hydrofluorocarbons and certain substitutes.” Among the rule’s additional provisions are considerations regarding the servicing, repair, and installation of equipment using recycled HFCs as well as mandates related to technician training and HFC disposal.

Specific Regulations from Final Rule

Included in the latest final rule are requirements for[i]:

• Leak repair of appliances that contain at least 15 pounds of a refrigerant that contains an HFC or a substitute for an HFC with a global warming potential (GWP) above 53, with specific exceptions;
• Installation and use of an automatic leak detection (ALD) system for certain new and existing appliances containing 1,500 pounds or more of a refrigerant that contains an HFC or a substitute for an HFC with a GWP above 53;
• A reclamation standard limiting the amount of virgin HFCs that can be contained in reclaimed HFC refrigerants;
• The servicing and/or repair of existing equipment in certain refrigeration, air conditioning, and heat pumps (RACHP) subsectors to be done with reclaimed HFCs;
• The servicing, repair, disposal, or installation of fire suppression equipment that contains HFCs, with the purpose of minimizing the release of HFCs from that equipment, including requirements for the initial installation and servicing and/or repair of fire suppression equipment to be done with recycled HFCs, as well as requirements related to technician training in the fire suppression sector;
• Removal of HFCs from disposable cylinders before discarding; and
• Recordkeeping, reporting, and labeling

Exemptions for this rule include “mission critical military end uses” and “on board aerospace fire suppression.”

Also included in the final rule was an EPA amendment to a separate regulation, “Resource Conservation and Recovery Act (RCRA),” which would establish alternative standards for ignitable spent refrigerants when “when recycled for reuse,” as the term is to be defined under RCRA. The amendment would establish that the alternative standard from the relevant section (40 CFR part 266, subpart Q) of RCRA “apply to HFCs and other substitutes that are lower flammability (i.e., that do not belong to flammability Class 3 as classified by the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE).

As written, this amendment would, in simple terms, codify the suitability of A2L refrigerants as alternatives to nonflammable HFC refrigerants like R-410A.

Provisions not finalized by the final rule would include those “requiring the initial installation of refrigerant-containing equipment in certain subsectors in the RACHP sector to be done with reclaimed refrigerant where HFCs or a blend containing HFCs are used,” as EPA claims it plans to further consider such provisions and comments received on the topic before establishing a plan to proceed.

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[i] https://www.epa.gov/system/files/documents/2024-09/prepublication-final-err-rule.pdf